Last Updated: November 4, 2020
You do not have to provide us with any Personal Data to visit the public portions of the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site, or access the educational services offered by CSI.
Types of Data Collected
We gather your Personal Data and Other Data (as described below).
Collection of Personal Data
Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number (“Personal Data”). We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so.
- CSI requests Personal Data from you when you register for educational services on the Site. The registration process requests that you provide Personal Data, such as your name, date of birth, email address, business address, phone number, and company affiliation, and agree to the terms and conditions presented at the time of registration.
- CSI may collect Personal Data voluntarily provided by you, including in emails, online forms, order and registration forms, surveys, promotion participation, online chats, phone calls, and through other means, including the testing, performance and completion data related to any courses and/or seminars you enroll in as part of the educational services provided by CSI.
- CSI may request Personal Data from our customers to comply with applicable anti-money laundering laws and other applicable laws.
- In some cases, your employer (or other organization that is sponsoring your registration in the educational services provided by CSI) may provide your Personal Data to CSI on your behalf CSI.
- CSI collects information through various other means, including searches online, participation at conferences and events, individual introductions, from employers that enroll their employees in our services, and from selected third-party business partners. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services.
Use of Personal Data Collected
We use Personal Data for legitimate business purposes, including the following:
- Fulfillment of Requests. CSI may use Personal Data about you to deliver educational services to you, and to provide you with information about services you’ve ordered. We will engage in these activities to manage our contractual relationship with you and to fulfil our contractual obligations.
- Reporting to Regulators. CSI is requested in various cases to provide information to securities industry (and other) regulators that our students may be registered with, seeking registration with or are otherwise governed by (including but not limited to the Investment Industry Regulatory Organization of Canada or “IIROC”). CSI may provide your Personal Data to such regulators, including but not limited to, Personal Data sufficient to identify you, your course completion and course performance information, to the extent that such information is requested by the regulator. We will engage in these activities to comply with a legal obligation.
- Marketing Communications. From time to time, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If your employer is a CSI customer, we may also inform you of such products, programs, services and promotions using Personal Data about you that your employer provided to CSI. We may also use Personal Data of media contacts for press release distribution or sharing other newsworthy developments related to our business activities. If you would prefer that we not send electronic marketing messages to you, please see the “Your Choices” section below.
- Other Business Purposes. We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the efficiency of our services), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site, completing business transactions (for example, to confirm content requested is received by customers), development and delivery of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of the Site are of most interest to users), product development, conducting surveys and market research, and administering individual accounts.
- Compliance with law and regulation. We may use Personal Data as necessary to comply with applicable legal and regulatory requirements such as sales tax collection, audits, etc.
- Where required by applicable law, we will only use Personal Data with your consent.
Collection and Use of Other Data
- Monitoring Data. CSI and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of the Site (“Monitoring Data”). We use Monitoring Data to help us understand who uses the Site and to improve and market it, as well as our other web sites and services.
Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
- Aggregated Data. We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.
- We do not respond to browser do-not-track signals at this time.
- IP Addresses. When you visit and interact with the Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how the Site is used by our users, to improve the Site and to enhance user experience of the Site. We may also derive your approximate location from your IP address.
Disclosure of Personal Data Collected
We may disclose Personal Data for the following purposes:
- Paying Employer or Third Party. If your employer (or other third party) pays for your enrollment and/or participation in any educational services provided by CSI (either by way of payment directly to CSI or personal reimbursement to you of amounts paid to CSI), CSI may, from time to time at the request of such employer or third party, disclose to the employer or third party your performance data related to the particular educational services that such employer or third party has paid for. This only applies to the particular employer or third party that paid for the educational services to which the request for your performance data relates – a request for such performance information made by a subsequent employer or third party will be denied absent your express consent to such disclosure. To provide a general consent to disclosure of your performance data to employers that may request it from time to time, please login to your student profile through www.csi.ca and accept the information release consent form (the “IRCF”).
- Reporting to Regulators. Regulators may request that CSI provide information about licensed registrants or students who apply to be registered with the regulator or are otherwise governed by the regulator (including but not limited to IIROC) and CSI will provide this information. There are also rare occasions where CSI will report events to IIROC or other such regulators (e.g., in the case of significant academic infractions).
- Third-Party Service Providers. We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, data analysis, order fulfillment, payment processing, provision of educational materials, provision of course completion certificates, course instruction and/or administration, examination and testing administration and other services.
- Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with CSI to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded web sites (“co-branded pages”). Any information, including Personal Data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners. You should check these third parties’ web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.
- Third-Party Data Providers. If you subscribe to a CSI product or service that contains third-party data, we may be required to provide your Personal Data to the third party as part of our reporting obligations. We will only do so if a third-party data provider conditions your receipt of their data on knowing your identity.
- Conferences and Events. When you attend a conference or event organized by CSI, your name and contact information may be shared with other attendees and co-hosts of the conference or event.
- Promotions. We may share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to those Promotions.
- Qualification Publications. From time to time, CSI may publish lists of individuals (online or otherwise) that have completed various courses or certificates and/or hold various professional designations offered and maintained by CSI. Individuals may be identified by their name and business affiliations in such publications
- Assignment. We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
If you would like to receive more information on the third parties with whom we share your Personal Data, please contact us by using the information provided in the “Contact Information for CSI” section below.
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.
- If you wish to alter the manner in which your Personal Data is used by CSI to send marketing communications, please login to your profile through www.csi.ca and visit the CSI Email Preference Centre.
- If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by sending an e-mail to email@example.com.
- If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an e-mail to firstname.lastname@example.org.
We will comply with your request(s) as soon as reasonably practicable, and in accordance with applicable law. Further, please note that requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing emails from CSI. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.
You may also indicate your choices regarding marketing-related emails by contacting us via postal mail or telephone using the information in the “Contact Information for CSI” section below, or if you have a Site profile/account, by changing your preferences on your Site profile/account at any time.
Note that from time to time, CSI receives education verification requests from third parties seeking information regarding our students’ academic records. Other than as set out herein, CSI will not provide such information to third parties unless you have affirmed the IRCF referred to above.
How You Can Access, Change OR Suppress Your Personal Data
If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may make a request by accessing and completing a Personal Data Request Form. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion.
CSI has established reasonable organizational and technical measures to protect Personal Data within our organization from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Please note that while CSI has endeavored to create a secure and reliable Site for users, no site is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by contacting us using the information provided below in “Contact Information for CSI” (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Cross Border Transfer of Personal Data
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.
If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available on the EU Commission’s adequacy list online at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data. You may obtain a copy of these measures by contacting us using the information provided in the “Contact Information for CSI” section below.
If you are located in other countries, we will also ensure that we have appropriate legal grounds to perform cross-border transfers of your Personal Data. Where required in certain jurisdictions, we comply with requirements on initial processing of Personal Data with the use of databases located in the country of collection of your Personal Data.
Use of the Site by Minors
This Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through this Site.
Sensitive Personal Data Restrictions
Unless we specifically request for information to comply with applicable anti-money laundering laws and other applicable laws, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, passport numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.
Contact Information for CSI
1-866-866-2601 (Canada & USA) or 416-364-9130
Questions or concerns regarding CSI data protection practices should be addressed to:
7 World Trade Center at 250 Greenwich Street
New York, NY 10007
Phone: +1-212-553-1653 or 1-866-995-9659
Additional Information for the EEA
You may lodge a complaint with the data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs.
For Germany, you may contact our German Data Protection Officer by sending an e-mail to email@example.com with the subject heading “German Inquiry.”
Additional Information for California
If you are a resident of California, the California Consumer Privacy Act (“CCPA”) (Civil Code § 1798.100) provides you with specific rights regarding your Personal Data. These include:
- You can request information about our collection and use of your Personal Data over the past twelve (12) months concerning: (i) the categories of Personal Data we collected about you, (ii) the business or commercial purpose for collecting your Personal Data, (iii) the categories of sources from which your Personal Data is collected, and (iv) the categories of third parties with whom we share your Personal Data. You can request a list disclosing the categories of your Personal Data we have shared in connection with a business purpose.
- You can request to receive a copy of your Personal Data in a commonly used and machine-readable format.
- You can request that we delete your Personal Data, subject to certain exceptions.
To exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the Personal Data relates to you. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. We will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law.
During the past twelve (12) months, we collected the categories of Personal Data described above from California residents. We also disclosed such Personal Data to third parties for the purposes specified above during the past twelve (12) months.
CSI does not sell your Personal Data.
You may exercise any of the rights described in this section, by contacting us using the information provided in the “Contact Information for CSI” section above.
You may exercise any of the rights described in this section by accessing and completing a Personal Data Request Form.
Additional Information for Brazil
If you have any questions or comments regarding your rights under Brazil’s Lei Geral de Proteção de Dados (LGPD), please contact our Data Protection Officer. You can do this via email at firstname.lastname@example.org.